My comments in return...

Liz Allan, RHIA
San Jose, CA

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On
Behalf Of WALLIS Dwight D

This raises some interesting authenticity issues. If a PHR is providing
input into "the legal record of a provider", to what extent does that
provider then become responsible for the quality of the information
provided, and the consequent impact on the health decisions made? 
- Not all providers will accept patient input into their legal records
or, if they do, will segregate it for just this reason.

Also, its unclear to me how the PHR is constructed - is it from the
records of covered entities through the individual, or direct from the
covered entities to the PHR service provider (in this case, Google) on
behalf of the individual? 
- Depends on the PHR.  I would say that most PHRs are constructed by
individuals; Google is different in this regard because of the other
companies/providers that have joined in this particular effort.  

If either is the case, how are the records synchronized over time, and
who is responsible for ensuring that synchronization occurs, so that the
PHR accurately reflects the latest information from its "multitude of
sources"? 
- Good question, but I sure don't have the answer!

What if a covered entity's records are destroyed - does that occur also
to the information in the PHR? 
- Probably not.  Think of Katrina, when the providers records (and the
providers) residing in the area were destroyed/displaced.  The VA's
electronic records (backed up elsewhere) remained available.
 
Finally, I wonder how, from a cost standpoint, this might be construed
by covered entities? Would they have a financial incentive to do what
they can to transfer record keeping responsibility to a non-covered PHR,
thereby lessening their records keeping cost burdens (which one would
assume are more onerous because of their status as covered entities)?
- No.  The providers have their own federal/state/local/professional
rules and regs to follow regarding record keeping and I don't think they
would get any financial or legal relief.  They might instead have more
legal exposure, but I am not a lawyer so cannot say for sure.  And
remember, covered entities are not just providers - insurance companies
are covered entities too.



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